Lloyd's Manual

Conversion: partnerships: treatment of stop loss premiums

On the other hand, a premium on a stop loss policy taken out by the partnership, as Lloyd’s member, that reinsures partnership losses and makes payments to the partnership is an allowable expense, and similarly any recoveries are taxable. But a premium that insured only one member of the partnership and paid out to the individual partner would not be allowable, whether the premium was paid by the partnership or by the individual member.